Joan H. Email and Phone Number

Prepare preliminary drafts of pre-mediation reports and pre-trial reports.Meet with defendants and review claim file to garner information to prepare initial draft of answers to interrogatories and requests for production.Review plaintiff’s discovery responses and prepare summary letter to adjuster.Review medical records and discovery responses from plaintiff to locate additional medical providers and entities in furtherance of discovery and defense of case.Draft Motions to Compel discovery responses and other motions.Propound discovery including request for admission, interrogatories and request for production on plaintiff.Conduct research for Lexis Nexis, Comprehensive Person Reports and review and prepare summary.Review Social Media Reports and prepare summary to adjuster.•Review driving and crash history of plaintiffs and prepare summary letter to adjuster.Draft proposed Agreed Orders and file on Courtmap or Online Services.•Schedule compulsory medical examinations and prepare and send records to expert physicians.Review trial orders and prepare witness and exhibit lists.Prepare trial exhibits in preparation for trial.Efile pleadings in Florida circuit court.

Review plaintiff’s medical records and prepare medical chronology.Prepare initial draft of answers to interrogatories and requests for production with standard objections.Review medical records and discovery responses from plaintiff to locate additional medical providers and entities in furtherance of discovery and defense of case.• Draft subpoenas, pleadings including motions for litigation cases and draft and propound discovery including interrogatories, and request for production on plaintiff.Review claim file to ascertain pertinent information in furtherance of discovery.Draft letters of representation to clients and correspondence to judges, attorneys and clients.Schedule depositions, mediations, hearings and meetings for associate.Draft proposed orders. Efile pleadings in Florida circuit court.

Review documents from clients and nursing home charts to garner information to prepare initial draft of answers to interrogatories and requests for production. Review medical records and discovery responses from plaintiff to locate additional medical providers and entities in furtherance of discovery and defense of case. Draft subpoenas, pleadings including motions for litigation cases and draft and propound discovery including interrogatories, and request for production on plaintiff.Draft pre-suit discovery to claimant and responses to pre-suit discovery.Review claim file to ascertain pertinent information in furtherance of discovery.Draft letters of representation to clients and correspondence to judges, attorneys and clients.Schedule depositions, mediations, hearings and meetings for managing partner. Draft proposed orders and file on Courtmap or Online Services. Efile pleadings in Florida circuit court. Draft various pleadings, correspondence, HIPAA authorizations and subpoenas. Review claims file and records in furtherance of defense and discovery of cases. Review cases and maintain deadlines. Maintain communications with clients and keep clients abreast of discovery and upcoming deadlines. Review cases and retrieve documents for expert witnesses. Coordinate hearings and depositions with opposing counsel.

Attended client meetings and document signings and drafted Wills, Advance Directives for Health Care and Power of Attorney. Prepared stock certificates. Drafted correspondence and engagement letters for new clients. Drafted Petition for Order Declaring No Administration. Prepared diagrams of estate planning documents.

Reviewed complaints and accident reports and opened new matters. Communicated with clients and drafted responses to interrogatories and requests for production of documents. Reviewed medical records and prepared medical summaries. Analyzed bills and prepared special damages. Drafted open records requests letters and requests for production of documents to non-parties. Scheduled depositions and maintain docket of all deadlines. Researched statutes for relevant information and inserted appropriate statutes in correspondence. Reviewed responses to discovery from opposing counsel and responses to open records requests and updated case in Aderant Total Office.

Reviewed all legal documents served and forwarded to attorney and managers. Managed bankruptcy case files. Monitored Pacer for bankruptcy documents and status of cases. Analyzed bankruptcy plans and updated bankruptcy spreadsheets in Excel. Managed docket for hearings and proof of claim deadlines. Met with outside counsel to discuss case files and bankruptcy plans. Modified agreements for homes held in trust. Created and updated files. Contacted trustee and attorneys regarding debtor's cases. Forwarded foreclosures for potential recuperation of equipment.

Functioned as floor coordinator and team lead by serving as a liaison between Human Resources and support staff. Formulated team-building exercises and chaired meetings with administrative staff. Distributed and communicated information to department/floor. Delegated overflow work to administrative staff and word processing. Analyzed invoices for accuracy and forwarded to clients. Retrieved billing summaries and prepared invoices for closing. Reviewed title commitments and documents and assembled title commitment binders. Requested checks and forwarded documents to court for recordation. Composed and typed correspondence. Generated redline comparison word documents. Formatted and typed real estate agreements and other legal documents. Coordinated conference and travel arrangements. Prepared expense reports. Opened new clients and matters in iMatter. Entered attorney hours in Expert Time.

Maintained corporate minute books and processed corporate dissolutions. Reviewed agreements and created summary of requirements. Drafted and prepared business associate agreements. Prepared PowerPoint presentations and conducted HIPAA presentations for employees and administrators of nursing homes and corporate office. Composed HIPAA breach letters to residents. Reported HIPAA breaches on Department of Health and Human Services website. Served as Compliance Officer for company by documenting compliance complaints and discussing complaints with Compliance Committee. Compiled annual compliance report. Generated Excel spreadsheets relating to HUD Reserve for Replacement funds. Prepared and filed answers to garnishments. Corresponded with various outside counsel and coordinated responses to HIPAA breaches, preparation of garnishments, revisions to compliance handbook and other legal documentation. Designed various template correspondence for nursing home administrators. Renewed annual Secretary of State registrations for 55 entities. Filed documents and emails in electronic database.

Modified/redlined construction agreements. Updated and filed construction license and annual reports in various states for multiple Bovis entities. Scheduled conference calls, managed calendars and arranged meetings. Coordinated travel arrangements and created expense reports. Updated and distributed monthly litigation reports and maintained litigation files and other legal files. Processed invoices and updated outside counsel invoice spreadsheet. Prepared PowerPoint Presentations. Interacted and communicated with internal clients and outside counsel.

Modified/redlined subscriber agreements. Scheduled conference bridge, managed calendars and arranged meetings. Made travel arrangements. Updated and distributed monthly litigation reports and maintained litigation files and other legal files. Updated spreadsheet for outside counsel invoices. Prepared PowerPoint presentations. Interacted and communicated with internal clients and provided back-up telephone support to the CEO.

Drafted engagement letters and prepared form letters. Composed and typed correspondence. Took inventory and order supplies. Entered attorney hours. Completed and compiled patent forms for US and PCT patent cases. Edited patent applications. Prepared draft responses to office actions. Coordinated travel arrangements and managed partner’s calendar. Scheduled meetings with clients.

Completed and compiled patent forms including Information Disclosure Statements, Fee Transmittals, and Assignments for US and PCT patent cases. Composed and typed correspondence and finalized drafts of correspondence. Coordinated conference and travel arrangements. Prepared expense reports. Prepared check requests for invoices. Entered attorney hours.

Prepared non-disclosure and consulting agreements. Modified/redlined construction, architectural and engineering agreements. Composed and typed correspondence. Typed correspondence from dictation or typed drafts. Transcribed voice mails. Scheduled meetings and telephone conferences with domestic and international associates, outside counsel and vendors/contractors. Scheduled domestic and international travel arrangements. Modified presentations. Completed and compiled patent forms. Coordinated patent filing process with inventors and outside counsel. Entered attorney hours.

Formatted and typed mortgage instruments, loan agreements and correspondence from dictation or typed drafts. Arranged on-site and off-site departmental meetings, scheduled conference calls and maintained manager’s calendar. Developed and maintained marketing projects database. Scheduled conference registration and travel arrangements. Entered attorney hours on PALS database. Audited and processed Department’s Visa purchasing card statement.